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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

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List of Q&A's

Calculation of the amount of holdings of own Common Equity Tier 1 instruments on the basis of the net long position

Could it be assumed that short positions maintained with a Qualifying Central Counterparty do not involve counterparty risk according to Article 42 a) i) CRR and thus be netted for the purposes of the calculation of the amount of holdings of own Common Equity Tier I instruments to be deducted under point (f) of Article 36(1)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6409
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2023

Calculation of goodwill included in the valuation of significant investments in insurance undertakings

A. For the purposes of a deduction under Article 36(1)(b) CRR as per Article 37(b), should the goodwill (Article 4(1) no. 113 and 115 CRR) included in the valuation of significant investments calculated excluding goodwill booked under an insurance subsidiary given that this goodwill is not included in the valuation of a significant investment of the bank (i.e. goodwill not included in the prudential consolidation as per Articles 1, 11, 18 and 24 of CRR and EBA RTS on the methods of prudential consolidation)?  B. Can you confirm that the goodwill booked under an insurance subsidiary (which is excluded from the valuation of significant investments as per prudential consolidation) should be treated as part of the equity exposure of the bank to the insurance subsidiary and this be risk weighted as per Article 49(1) and Articles 133 or 155 (depending on Standardized or Advanced IRB method)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6408
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 26/07/2022

Own credit risk

Should own credit risk be considered in the Alternative Standardised Approach of the FRTB?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6406
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 26/07/2022

C 33.00: Instructions concerning specific positions - c0020

Should column 0020 in C 33.00 be filled in as the sum of the columns 0030 to 0120 minus column 0130? Or should the net amount only be reported when the following condition is met: there’s a short position with the same immediate counterparty and residual maturity? If the current definition of column 0020 is considered correct, should validations v10651_m and v5853_h be changed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2022_6407
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 27/01/2023

Scope of CRR definition of Financial Institution

Are deposits maintained by entities meeting the literal requirements of Article 4(1)(26) CRR excluded from the coverage of the Deposit Guarantee Schemes (DGS)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6405
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

EAD value for CVA calculation

Is the the EADiTotal in paragraph 1 gross of or net of incurred CVA. The definition provided by the regulation states that the effect of the collateral should be included but there is no reference as towards the incurred CVA regognised by the Bank as a write-down which under article 273 par.6 is applied in the calculation of the CCR RWA. "EAD total i = the total counterparty credit risk exposure value of counterparty ‘i’ (summed across its netting sets) including the effect of collateral in accordance with the methods set out in Sections 3 to 6 of Title II, Chapter 6 as applicable to the calculation of the own funds requirements for counterparty credit risk for that counterparty. An institution using one of the methods set out in Sections 3 and 4 of Title II, Chapter 6, may use as the fully adjusted exposure value in accordance with Article 223(5)."

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6404
  • Topic: Market risk
  • Date of submission:

LCR: Eligibility of HQLA held at EU subsidiary level for the consolidated HQLA liquidity buffer

Do credit institutions need to take into consideration as potential restrictions on the transferability of liquidity within the EU the (national) prudential rules that are not intended to restrict transferability of liquid assets but in practice may do so when assessing whether or not a liquid asset can be deemed readily accessible to a credit institution at consolidated level within the meaning of Article 8(2) LCR DR? For instance, do national statutory large exposures limits established by Member States pursuant to Article 493(3) CRR or statutory capital requirements at individual level more generally constitute such practical or legal impediment from consolidated perspective?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2022_6402
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Securitisation - application of look-through methodology

Should a bank follow the same approach for representing the exposure underlying a securitisation in Larex (large exposures reporting) as in COREP?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1187/2014 - RTS for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets
  • ID: 2022_6401
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 16/02/2023

Validation rule v4821_m on column c0230 of Template C.08.02.

We wonder if there could be possible exceptions to the Validation rule v4821_m which always requires the LGD reported in column c0230 of Template C.08.02 by Obligor Grades to be always lower than or equal to 1.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2022_6400
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 13/10/2022

v7386_m and v7387_m (COREP)

  We wonder about the consistency of validation rules v7386_m and v7387_m, which are set to verify that columns 0431 and 0432 of template C 14.01 should always be equal to or higher than columns 0900 and 0910 of Template C 13.01, respectively.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2022_6399
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 28/10/2022

Deduction of indirect holdings of own funds instruments in insurance and reinsurance undertakings which are subsidiaries of insurance holding company from own funds

Should indirect holdings of own funds instruments in insurance and reinsurance undertakings which are subsidiaries of insurance holding company be subject to the exemption provided for in Article 15a(2)(a) of Commission delegated regulation No 241/2014?   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2022_6398
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Validation rule v7371 - Securitization Template C 14.00

Should validation rule v7371 be a blocking error in case of a securitisation transaction under a replenishment period?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2022_6397
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 13/10/2022

Mandatory substitution approach according to Articles 401(4) and 403 CRR for Lombard Facilities

Could you please clarify the applicability of Article 401(4) and 403(1)(a) for other funded credit protection such as life insurance policies pledged to the lending institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6396
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Calculation of a Prudent Value in combination with CET1-Deduction according to article 89 and 90 CRR

In case of applying article 89 CRR in combination with article 90 CRR for a risk exposure (asset) is there a requirement of calculating an additional valuation adjustument (AVA) although the calculated amount of CET1-deduction of the risk exposure already lowers CET1?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2022_6395
  • Topic: Market risk
  • Date of submission:

Risk weight for asset class of non-preferred senior debt

What risk weight should be applied to non-preferred senior (NPS) debt, under the standardised approach for credit risk? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6394
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/06/2022

Validation rule v09823

Is the validation rule v09823 correct? How would you understand and interpret the validation rule?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
  • ID: 2022_6393
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 13/10/2022

API functionality

Is it allowed to use a dedicated PSD2 interface by a TPP that identifies itself with an eIDAS certificate for purposes other than those specified in Article 30(1)(b) - (c) of the RTS on strong customer authentication (SCA) and secure communication? 

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2022_6392
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/10/2022

Paper-based postal money orders as defined by the Universal Postal Union

1. Should postal transfers as defined by the Universal Postal Union, which are not made in paper form but by electronic means, be excluded from the scope of PSD2?     2. If postal transfers, as defined by the Universal Postal Union, in both electronic and paper format, are inseparable from the postal operator’s accounting system, should also paper-based postal transfers not fall outside the scope of PSD2?     3. Should such transfers be excluded from the scope of PSD2 in either case, or agree that the payment institution is not entitled to credit those funds to the payment service customers’ funds accounts where the money of the payment service users is kept separate?     4. Can a payment institution that is also a postal service provider simultaneously provide both PSD2 regulated services and services related to payments but outside the scope of PSD2?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6391
  • Topic: Other topics
  • Date of submission:

Validation rule v1376

Is validation rule v1376 applicable when Achmea Bank amortizes the fee expenses, and the intercompany party does not amortizes related fee expenses? As a result of the amortisation, the intercompany fee expenses is greater than the total fee expenses.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2022_6390
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 12/10/2022

Amortised amounts of tier 2 capital instruments as source of ASF

Can the amortised amounts of tier 2 capital instruments (as per Article 64 CRR) be included among other capital instruments (as per Art. 428o (d) CRR) for the purpose of calculating available stable funding (Part Six, Title IV CRR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6389
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 21/12/2022